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TMI Blog1982 (9) TMI 157X X X X Extracts X X X X X X X X Extracts X X X X ..... plied the ITO within time for the issue of challan for payment of fee for filing the appeal before the Appellate Tribunal but such a challan was received by him only in June, 1982 and that in the circumstances the delay was unavoidable. The correctness of this submission has not been satisfactorily controverted by the revenue. I am, therefore, satisfied that there was sufficient cause for the dela ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e, the ld. Counsel for the assessee vehemently urged the ITO as well as the AAC did not dispute the factum of the payment of salary to the aforesaid two persons. He pointed out that the ITO did not disallow the claim on the ground that no services were rendered by them and that the AAC had erred in holding that the members aforesaid did not render any service to the assessee. On behalf of the reve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f Jugal Kishore Baldeo Sahai vs. CIT reported in (1967) 63 ITR 238 (SC) supports the above view. I find also that for the immediately preceding asst. yr. 1976-77, a total salary claim of Rs. 5,419 was allowed by the revenue. For the year under appeal viz. 1977-78 apart from the claim of Rs. 6,000 under dispute there was no other claim for salary to any other person. Having regard to the circumstan ..... X X X X Extracts X X X X X X X X Extracts X X X X
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